OSHA Injury Reporting

Near misses, unsafe behaviors, unsafe conditions, slips, trips, mistakes take place every day Sometimes these hazardous conditions result in somebody getting injured But we have been trained as EHS professionals that these injuries are just the tip of the iceburg. Manny factors are taking place behind the scenes (under water) that manifest into an injury occurring.

Heinrich accident triangle This isn’t a new theory Herbert William Heinrich is an American industrial safety pioneer from the 1930 80 years ago, Heinrich published the accident triangle EHS Mission Statement Under the Occupational Safety and Health Act of 1970, OSHA's role is to assure safe and healthful working conditions for working men and women

EHS mission: to assure safe and healthful working conditions for the MIT community. OSHA CFR MIT EHS MIT EHS core function is the same as OSHA Under the Occupational Safety and Health Act of 1970, OSHA's role is to assure safe and healthful working conditions for working men and women Point out 1904 1910 1926

Joe MacLeod & Suzanne Adams OSHA Injury Reporting Joe MacLeod & Suzanne Adams This presentation represents a portion of the EHS management system and is represented by this diagram Everyone in this room plays a vital role in this management system

OSHA CFR 1904 Requires employers to establish a procedure for employees to report injuries and illnesses All employees on your payroll; labor, executive, hourly, salary, part-time, seasonal, or migrant workers. Employees who are not on your payroll if you supervise these employees on a day-to-day basis. Employee representatives have access to those parts of the OSHA 301 form relevant to workplace safety and health Requires specific information to be reported. Regulatory requirement black and white Common sense? We all are in place to eliminate hazards and prevent injury Employers are prohibited from discriminating against employees who do report DPS notification for injuries resulting in hoisting (elevator) malfunction MIT OSHA citation 2 years ago on recordkeeping

Basic accident and employee information used for nationwide trending / demographics, statistics BLS survey suzanne will mention OSHA Form 301

OSHA Form 300

Summarize your organizations findings on this form OSHA 300A

MIT manages this recordkeeping requirement through SAP And all of the useful toy and tools associated with SAP, SAP gui, and of course brioquerry

2010 MIT Numbers Recordable 196 Incident Rate 1.9 LT Incident Rate 0.93 Days lost 1522* Days restricted 1344 400 reported injury/illnesses, 196 recorded

OSHA recordable injuries / illnesses Number of programs in place to drive these numbers down HR return to work program DOF return to work / light duty program

Incidence Rates of Recordable Injuries and Illnesses Numbers continue to get more and more accurate as we triage every accident report submitted to determine if it meets OSHA recordability standards Triage process continues to fine tune and identify the MIT workforce per OSHA guidelines

MIT Incidence Rate of Cases with Days Away from Work 0.93 These numbers will fall as we tighten up our management of injuries Return to work programs Modified duty / light work programs

Roles and Responsibilities Employee Supervisor DLC Coordinator EHS Lead Contacts Medical Provider HR Worker’s Compensation OSHA Recordkeeping The players in the management system

Employee Notify supervisor Seek treatment Provide medical documentation to supervisor Communicate work status Provide information on potential hazard/s in the workplace Orientation Safety committees Union representatives Shop stewards

Supervisor First line of defense in the management system Ensure employee can get help Address hazard Submit supervisor report of injury Investigate hazard and complete follow-up investigation questions* Follow the incident through until “return to work without restrictions” First line of defense in the management system Address hazards: Clean spills, contact cust-coach, cordon off area, contact EHS / coordinator Suzanne is there to “remind” supervisors if they forget to track DOF recently reviewed this responsibility and is in the process of re-training supervisors on their responsibilities Supervisors must maintain an open line of communication with the injured party *(DLC coordinators help with this)

Supervisor Follow-up questions What caused the accident? Improvements to behavior (PPE, JHA,) Conditions (defective equip., housekeeping, guarding How to prevent re-occurrence? Training, SOP (create / modify), install shielding Other relevant information? Basis for all accident investigation is Who, What, Where, When, how Supervisors are encouraged to utilize others within the management system (EHS, Coordinators, Lead contacts) After a few days of thinking about incident, then submit the follow up questionnaire (5-day report). Goal is to identify root causes and put controls into place Our goal as EHS professionals should be 0 accidents / injuries DOF has incorporated this into their incident reporting procedures

DLC Coordinators/EHS Lead Contacts Notified immediately via e-mail when on line report is submitted (Privacy cases) Provide technical assistance to supervisor investigation* Ensure hazard is addressed Facilitate completion of supervisor’s report Ensure action items are completed (maintenance, training, procedure updates) Investigate trends repetitive strain, lifting, frequent fliers, facility knowledge Privacy issues 2010 – 3/400 reported cases were private Some injuries require EHS investigations ENGAGE MANAGEMENT SYSTEM-COORDINATORS MANAGE EHS ACTIVITIES IN DLC COORDINATORS MANAGE SUPERVISORS ENSURE INVESTIGATIONS ARE COMPLETE AND DLC ARE HAZARD FREE Any Questions?...Note the first bullet

Medical Provider All employees should go to MIT Medical for their first visit if they are physically able to (with supervisor assistance) - Cases with ambulance, off hours and emergencies Employee seeks treatment before reporting the injury to the supervisor (outside medical provider) Evaluates injury / work capability & makes recommendations Provides documents for lost time/restrictions/return to work status for employee and supervisor MIT medical policy for work related injuries/initial evaluation

HR Worker’s Compensation Managed in Human Resources Strictly employee based Collects all medical paperwork Keeps track of lost time and medical treatment billing Refer to the handout for specifics

WARNING: DO NOT MIX OSHA RECORDABILITY AND WORKERS’ COMPENSATION Workers’ Compensation determinations do NOT impact OSHA recordability. Some cases may be OSHA recordable and compensable. Some cases may be compensable, but not OSHA recordable. Some cases may be OSHA recordable, but not compensable. OSHA stops counting at 180 WC can go on for years.

OSHA Recordkeeper Triage the Supervisor Reports of Injury Injury and Illness Report (OSHA 301) Employee Status Determine if work related Recordable vs. Not recordable OSHA Log (OSHA 300) Summary (OSHA 300A) Reporting to the BLS 388 reports submitted 196 made it onto the OSHA log so about half

All employees on payroll and supervised on a day to day basis…like Next Source Stipends-Grad students

Work-Related? YES NO (9 Exceptions) An event or exposure in the work environment either caused or contributed to the resulting condition An event or exposure in the work environment significantly aggravated a pre-existing injury or illness Present as a member of the general public Voluntary participation in wellness program, medical, fitness or recreational activity Personal tasks outside assigned working hours Personal grooming Eating, drinking or preparing food or drink for personal consumption   9 Exceptions but here are some common ones Reports not recorded about 15% are not work related.

Recordable? Mention triage process – Determining work related?

General Recording Criteria Triggers for Recording Death Loss of Consciousness Days away from work Restricted work or transferred to another job Needle sticks (some) Medical Treatment beyond first aid Sutures/glue Physical Therapy Prescription Medication Removing foreign body from eye w/ more than flushing/cotton Rigid splint Broken bones and fractures Needle sticks-contamination by another person’s blood or other potentially infectious material Reports not recorded 80% are not because it was a first aid only.

Notification Employers must record each case on the OSHA 300 Log and the Form 301 Incident Report within seven (7) calendar days after being notified that an injury or illness occurred. Employers must use calendar days (including holidays and weekends) instead of scheduled work days, for recording days away from work [1904.7]. Employers may cap days away from work at 180 days.

Questions or Comments?

Why are employers required to keep records of work-related injuries and illnesses? Injury and illness statistics Inspectors MIT Safety and Health programs Analysis of the data The records provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses. Statistics-used by OSHA to help direct its programs and measure its own performance. Inspectors- use the data during inspections to help direct their efforts to the hazards that are hurting workers. EHS where to direct efforts Analysis of data-is a widely recognized method for discovering workplace safety and health problems and for tracking progress in solving those problems